1. Acquisition tax, 56,316,450 won, registration tax, 56,263,820 won, and local education tax, which the Defendant paid to the Plaintiff on July 31, 2014 by the Plaintiff.

1. Details of the disposition;

A. B operated a private company with the trade name “D” in Gwangju City, and on October 18, 2010, the Plaintiff, a stock company, was established.

B. The total number of shares issued at the time of incorporation by the Plaintiff is 101,000 shares, and the value per share is 5,000 won and the Plaintiff’s capital is 505,00,000 won.

C. On October 19, 2010, B entered into a contract for transfer and takeover of business (hereinafter “instant transfer and takeover contract”) with the Plaintiff that the Plaintiff comprehensively takes over all rights and obligations with respect to the D business operated by B between the Plaintiff and the Plaintiff.

On October 20, 2010, pursuant to the instant transfer agreement, the Plaintiff acquired a transfer of “D-based factory site C, 4,200 square meters,” and “2389.02 square meters of above-ground buildings,” and “320.6 square meters of above-ground buildings (retail stores) in Gwangju-si,” and completed the registration of transfer on November 24, 2010.

E. On November 23, 2010, the Plaintiff filed an application for reduction or exemption of acquisition tax, etc. on the instant real estate on the ground that it is a business property acquired by comprehensive business transfer or takeover to the Defendant. On November 24, 2010, the Plaintiff was exempted from total of 61,404,240 won, including acquisition tax, pursuant to Articles 119(4) and 120(5) of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter the same).

F. However, on May 23, 2014, the Defendant confirmed that part of the assets B was excluded from those subject to the transfer of business, and notified the Plaintiff of the imposition of total of KRW 121,642,820 (including additional taxes) including acquisition tax.

G. Accordingly, the Plaintiff requested the Governor of the Gyeonggi-do to review the legality of the taxation before imposing tax, which is unfair, and the Governor of the Gyeonggi-do on July 28, 2014, rendered a decision not to adopt the Plaintiff’s request for review of legality on the ground that “B cannot be deemed to have comprehensively transferred all rights and obligations with respect to the business within three months.”

H. The defendant.